FINAL
Analysis
of
Groundwater
Monitoring
Data
Submitted
by
the
American
Portland
Cement
Alliance
Response
to
EPA
Contract
No.
68­
W­
99­
001
WA
231
Submitted
to:

Eastern
Research
Group
2200
Wilson
Blvd,
Suite
400
Arlington,
VA
22201
Submitted
by:

Tetra
Tech
EM
Inc.
1881
Campus
Commons
Drive
Suite
200
Reston,
VA
20191
i
TABLE
OF
CONTENTS
Section
Page
Part
I
–
Introduction
....................................................................................................................
I­
1
A.
Overview
.............................................................................................................
I­
1
B.
Summary
of
Available
Data
................................................................................
I­
2
Part
II
–
Analysis
of
Individual
Facility
Reports
........................................................................
II­
1
I­
1
Analysis
of
Groundwater
Monitoring
Data
Submitted
by
the
American
Portland
Cement
Alliance
I.
Introduction
This
report
contains
summaries
of
the
information
gathered
from
the
document
Cement
Kiln
Dust
Groundwater
Monitoring
Summary,
produced
by
the
American
Portland
Cement
Alliance
(APCA),
dated
October
2001.

A.
Overview
Eighteen
reports
were
evaluated.
Tetra
Tech
EM
Inc.
(Tetra
Tech)
attempted
to
determine
whether
claims
made
within
each
facility
report
were
justified
by
the
data
and
methods
found
within.
Tetra
Tech
also
looked
for
general
characteristics
of
groundwater
quality
related
to
potential
influences
from
cement
kiln
dust
(CKD)
activities
at
each
facility.
This
process
consisted
of
detailed
review
of
geographical
information
(i.
e.,
site
maps
and
descriptions),
geological/
hydrogeological
investigations,
historical
information,
sampling
methods,
analytical
methods
and
analytical
result
interpretation.

The
cement
kiln
dust
groundwater
reports
reviewed
herein
include
18
facilities
owned
by
10
companies,
spanning
10
states.
The
purpose
of
this
review
is
to
determine,
if
possible,
the
relative
influence
CKD
landfill
facilities
have
on
groundwater.
Tetra
Tech
reviewed
groundwater
data
and
compared
them
to
government
MCL
and
HBN
regulatory
values.
In
most
cases,
the
reports
submitted
by
the
APCA
were
not
detailed
enough
to
make
any
meaningful
determinations.
However,
Tetra
Tech
has
provided
a
descriptive
summary
of
all
available
data.
The
following
summaries
include
information
pertaining
to:

°
Groundwater
constituents
measured
°
Instances
where
groundwater
concentrations
exceeded
MCL
and
HBN
standards
°
Background
information
of
individual
site
(if
available)
°
Overall
quality
of
available
report
(content,
evidence
to
justify
conclusions,
etc.)

In
general,
a
reasonable
review/
assessment
of
the
influence
of
CKD
facilities
cannot
be
made
with
respect
to
these
file
reports.
In
order
to
provide
reasonable
reviews
of
groundwater
studies
at
CKD
facilities,
Tetra
Tech
recommends
that
the
submitted
investigative
reports
include,
at
minimum,
the
following:

°
Site
map
with
monitoring
well
and
source
area
locations
should
be
included
with
the
report
°
Groundwater
flow
direction
or
groundwater
elevations
°
Geologic
information
°
Monitoring
well
information
–
i.
e.,
depths
screened,
specifics
of
construction
°
Brief
site
history
is
suggested
–
historical
property
use,
use
of
surrounding
area,
past
environmental
assessments
conducted,
regulatory
history
°
Lab
and
field
QC
samples
(MS/
MSD,
duplicate
samples,
rinsate
samples,
blank
samples)
should
be
collected
and
results
listed
°
Analytical
methods
stated
and
should
be
EPA
approved
methods
(SW
846)
I­
2
°
Sample
collection
methods
should
be
stated
°
Filtered
or
not
filtered
metals
samples
collected
should
be
stated
°
Detection
limits
should
be
considerably
less
than
the
MCLs
°
There
should
be
a
consistent
list
of
base
line
substances
to
analyze
so
there
is
some
consistency
between
sites.
Some
sites
are
not
analyzing
for
substances
they
perhaps
should
be.
°
If
statistical
models
are
being
used
there
should
be
support
of
the
models
and
not
a
conclusion
statement
alone
°
If
there
were
soil
samples
collected
from
the
sources
areas
one
the
property
the
data
should
presented
to
determine
and
assess
the
groundwater
analyses
Examples
of
reports
that
did
meet
most
or
all
of
these
criteria
include
Lebec,
California
and
Midlothian,
Texas.
The
remaining
reports
appeared
to
be
either
partial
sections
or
abstracts
with
data
tables.
More
information
is
required
to
adequately
review
these
documents.

Based
on
the
limited
information
available,
Tetra
Tech
can
report
the
following
observations:

°
Several
facilities
indicated
elevated
levels
of
antimony,
arsenic,
beryllium,
cadmium,
lead,
selenium,
thallium
and
some
others
°
A
significant
number
of
the
reports
are
inconsistent
with
regard
to
sampled
constituent
(i.
e.,
parameter)
°
A
number
of
reports
do
not
include
parameters
of
potential
interest
to
the
EPA
(various
metals
and
inorganics)

B.
Summary
of
Available
Data
The
following
tables
show
how
the
available
data
compare
across
all
facilities.
Because
adequate
information
was
not
made
available,
there
is
no
comparison
between
background
(or
upgradient)
constituent
concentrations
and
downgradient
samples.
Some
comparisons
are
made
within
individual
site
reports
(next
section).
These
tables
also
indicate
what
constituents
were
sampled
at
each
site
(shown
by
"NA").

Table
1.
MCL
Summary.
This
table
reports
all
exceedances
by
facility,
each
constituent
that
was
not
sampled,
and
those
that
were
sampled
but
were
found
to
be
below
MCL
standards.
Note
that
in
some
cases
analytical
detection
limits
are
greater
than
MCL
standards.

Table
2.
HBN
Summary.
This
table
reports
all
exceedances
by
facility,
each
constituent
that
was
not
sampled,
and
those
that
were
sampled
but
were
found
to
be
below
HBN
standards.
Note
that
in
some
cases
analytical
detection
limits
are
greater
than
HBN
standards.
I­
3
I­
4
PART
II
ANALYSIS
OF
INDIVIDUAL
FACILITY
REPORTS
II­
1
Ash
Grove
Cement
Company
–
Chanute,
KS
Summary:
This
report
is
thorough
as
it
contains
historical
information,
subsurface
descriptions
(geology
and
geochemistry
of
groundwater),
permitting
history
and
documentation,
and
a
summary
of
groundwater
quality,
submitted
to
the
facility
by
ARCADIS
(Geraghty
&
Miller).

Table
1.
Overall
report
quality
Subsurface
description
Yes
Total
no.
of
wells
sampled
6
Sampling
dates
or
duration
Eight
sampling
events:
8/
98,
11/
98,
1/
99,
2/
99,
4/
99,
5/
99,
6/
99,
and
8/
99
Upgradient
wells
specified
2
Downgradient
wells
specified
2
Site
map
included
No
Adequate
physical
description
Fair
Contains
discussion
section
Yes
Contains
conclusions
Yes
References
cited
Yes
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
#>
Background
Inorganic
Chemicals
Alkalinity
N
­
NL
NL
­
­

Aluminum
Y
­
NL
NL
­
0.26
–
3
.66;
7
>
3.66
Ammonia­
N
N
­
NL
NL
­
­

Antimony
Y
0.002
to
0.04
0.006
0.014
60**/
60**
0.0021
–
0.07
0
>
0.07
Arsenic
Y
0.001
to
0.01
0.05
0.0000568
0/
72**
ND
–
0.007
5
>
0.007
Barium
Y
­
2
NL
0
0.14
–
0.22
22
>
0.22
Beryllium
Y
0.001
to
0.005
0.004
0.004
2/
55**
­

Bicarbo
nate
N
­
NL
NL
­
­

Cadmium
Y
0.005
0.005
NL
0
­

Calcium
Y
­
NL
NL
­
47.4
–
5
2.5
1
>
52.5
Carbonate
N
­
NL
NL
­
­

Chloride
Y
­
NL
NL
­
5.4
–
28
.5
5
Chromium
(total)
Y
0.005
to
0.01
0.1
40
1/
0
­

Copper
Y
0.01
1.3
1.0
0/
0
­

Fluoride
N
­
4
NL
­
­

Iron
Y
­
NL
NL
­
0.39
–
8
.4
3
>
8.4
Lead
Y
0.001
to
0.003
0.015
0.015
6/
6
ND
–
0.01
3
>
0.01
Magnesium
Y
­
NL
NL
­
37.3
–
4
1.0
1
>
41.0
Manganese
Y
0.01
NL
NL
­
0.026
–
0.171
3
>
0.171
Ash
Grove
Cement
Company
–
Chanute,
KS
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
#>
Background
II­
2
Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
­

Nickel
Y
0.005
to
0.04
0.1
NL
3
ND
–
0.02
3
>
0.02
Nitrate
(as
nitrogen)
N
­
10
NL
­
­

Nitrite
(as
nitrogen)
N
­
1
NL
­
­

Potassium
Y
­
NL
NL
ND
–
15.8
1
>
15.8
Selenium
Y
0.002
to
0.005
0.05
0.175
0/
0
ND
2
>
ND
Silver
Y
0.007
to
0.01
0.05
0.20
2/
2
ND
­
500
0
Sodium
Y
­
NL
NL
­
9.5
–
57
.0
47
>
57
.0
Sulfate
Y
­
NL
NL
­
14.4
–
1
7.8
30
>
17
.8
Thallium
Y
0.001
to
0.05
0.002
NL
60**
ND
–
0.145
Vanadium
Y
0.01
NL
0.3
0
­

Zinc
Y
0.02
NL
10
0
­

Field
Parameters
pH
Y
­
NL
NL
­
6.67
–
7
.5
18
>
7.5;
2
<
6.67
Conductivity
Y
­
NL
NL
­
6.82
–
700
12
>
700
TSS
N
­
NL
NL
­
­

Note
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
Based
on
the
report
which
is
not
dated
but
apparently
submitted
after
August
2001
by
ARCADIS
(Geraghty
&
Miller),
the
following
observations
have
been
made:

Conclusion
(1):
Hydrogeologic
conditions
at
the
site
are
not
conducive
for
collecting
representative
groundwater
samples;
therefore,
concentrations
of
metals
and
inorganic
parameters
are
highly
variable
over
time.

While
it
may
be
true
that
conditions
at
the
site
are
not
conducive
for
collecting
groundwater
samples
using
EPA­
approved
low
flow
sampling
procedures,
the
report
does
not
indicate
why
this
fact
would
result
in
highly
variable
concentrations
of
metals
and
inorganic
parameters.
What
evidence
exists
that
this
is
the
case
in
this
region?
A
reference
of
historical
studies
is
necessary
to
substantiate
this
conclusion.
Also,
since
attaining
representative
groundwater
samples
is
not
possible,
why
should
any
of
the
data
shown
in
this
report
be
acceptable?

Conclusion
(2):
The
results
of
the
statistical
evaluation
of
the
initial
two
years
of
groundwater
quality
data
indicate
that
none
of
the
14
metals
had
concentrations
which
indicated
a
Ash
Grove
Cement
Company
–
Chanute,
KS
(continued)

II­
3
statistically
significant
increase
over
background
conditions.
Therefore,
the
KDHE
did
not
require
ongoing
statistical
evaluation
of
additional
groundwater
quality
data.

Although
the
KDHE
decided
not
to
require
ongoing
statistical
evaluations
of
the
groundwater
data,
the
report
does
not
illustrate
the
degree
upon
which
the
observed
data
statistically
differs
from
background
conditions.
Again,
as
commented
under
Conclusion
(1),
if
the
hydrogeologic
conditions
are
not
conducive
for
collecting
representative
groundwater
samples,
are
the
background
samples
representative
of
background
conditions?
It
is
apparent
that
time
and
effort
has
been
expended
to
explore
background
conditions;
however,
the
report
needs
to
quantify
the
degree
of
uncertainty
of
all
of
the
reported
data,
as
well
as
the
statistical
evaluation
of
the
data.

Conclusion
(3):
Based
on
the
initial
statistical
evaluation
and
comparison
to
the
highly
conservative
Federal
MCLs
and
Kansas
HBLs,
a
release
from
the
CKD
landfill
is
not
apparent.

See
next
comment
(4).

Conclusion
(4):
Due
to
the
high
degree
of
variability,
a
long­
term
monitoring
program
and
possible
additional
statistical
analysis
will
be
required
to
determine
whether
releases
are
likely
to
occur
in
the
future.

Again,
the
report
does
not
attempt
to
quantify
the
degree
of
variability
that
is
supposedly
inherent
in
groundwater
constituent
measurements
in
the
vicinity
of
this
site.
There
is
no
statement
of
how
long
long­
term
monitoring
should
occur
in
order
to
reduce
uncertainty
to
acceptable
levels.
Therefore,
given
that
the
initial
and
recent
measurements
of
groundwater
quality
were
not
necessarily
based
on
long­
term
monitoring,
the
data
may
not
be
adequate
to
characterize
past
and
present
conditions
with
respect
to
the
landfill.
II­
4
Ash
Grove
Cement
Company
–
Montana
City,
Montana
Summary:
A
15­
acre
CKD
landfill
was
constructed
on
the
Ash
Grove
property
and
as
part
of
the
permitting
and
sighting
process
four
groundwater
monitoring
wells,
including
one
upgradient
well,
were
installed
adjacent
to
the
landfill.
The
report
states
that
there
is
no
evidence
that
leachate
from
the
landfill
is
impacting
local
groundwater.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
4
Sampling
dates
or
duration
3
times
(12/
18/
98,
6/
28/
99,
5/
11/
00)

Upgradient
wells
specified
1
(not
specified)

Downgradient
wells
specified
3
(not
specified)

Site
map
included
No
Adequate
physical
description
Limited
Contains
discussion
section
Limited
Contains
conclusions
Limited
References
cited
No
Table
2.
Summary
of
reported
data
Sampled?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#
>
Background
Inorganic
Chemicals
Alkalinity
Y
NA
NA
NL
0/
NA
234
–
251
0
Aluminum
N
NA
NA
NL
­
­

Ammonia
N
N
NA
NA
NL
­
­

Antimony
Y
0.003
0.006
0.014
2/
2
<0.003
–
0.008
0
Arsenic
Y
0.003
0.05
5.68E­
5
0/
7
<0.005
–
0.007
0
Barium
Y
0.005
2
NL
0/
NA
<0.005
–
0.036
8
Beryllium
N
NA
0.004
0.004
­
­


Bicarbo
nate
Y
NL
NA
NL
0/
NA
285
–
306
2
Cadmium
Y
0.0001
0.005
NL
0/
NA
<0.0001
0
Calcium
N
NA
NA
NL
­
­


Carbonate
N
NA
NA
NL
­
­


Chloride
Y
1.0
NA
NL
0/
NA
<1.0
–
5.18
9
Chromium
(total)
Y
0.001
0.1
40
0/
0
<0.001
3
Copper
Y
0.001
1.3
1.0
0/
0
<0.001
–
0.005
4
Fluoride
N
NA
4
NL
­
­


Iron
Y
0.01
NA
NL
0
<0.01
–
0.25
6
Lead
Y
0.003
0.015
0.015
3/
3
<0.003
–
0.016
3
Ash
Grove
Cement
Company
–
Montana
City,
Montana
(continued)

Sampled?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#
>
Background
II­
5
Magnesium
Y
0.005
NA
NL
0/
NA
<0.005
–
0.016
9
Manganese
N
NA
NA
NL
­
­

Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
<0.0002
0
Nickel
Y
0.02
0.1
NL
0/
NA
<0.02
0
Nitrate
(as
nitrogen)
Y
0.01
10
NL
0/
NA
1.51
–
1
.9
3
Nitrite
(as
nitrogen)
Y
0.01
1
NL
0/
NA
<0.01
2
Potassium
N
NA
NA
NL
­
­


Phosphorus
(total)
Y
0.01
NA
NL
0/
NA
<0.01
–
0.05
8
Selenium
Y
0.001
0.05
0.175
0/
NA
<0.001
2
Silver
Y
0.003
0.05
0.20
0/
NA
<0.003

<0.01
0
Sodium
N
NA
NA
NL
­
­


Sulfate
Y
NL
NA
NL
0/
NA
289
–
357
5
Thallium
N
NA
0.002
NL
­
­


Zinc
Y
0.01
NA
10
NA/
0
<0.01
4
Field
Parameters
pH
Y
NA
NA
NL
­
7.62
–
8
.1


Conductivity
Y
NA
NA
NL
­
952­
1,052


TSS
N
­
NA
NL
­
­


Dissolved
soilds
Y
NA
NA
NL
­
719
­
768


COD
N
­
NA
NL
­
­


Organic
Substances
(only
detected
substances
listed)

None
sampled

Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
The
text
states
that
there
is
one
upgradient
and
three
down
gradient
locations;
however,
no
specific
well
numbers
are
specified.
Names
of
the
monitoring
wells
are
provided.
The
well
listed
with
a
"U"
after
its
name
would
appear
to
represent
the
upgradient
location
and
the
wells
with
a
"D"
after
their
name
represent
the
downgradient.
Although
this
is
likely
and
assumed
for
performing
this
review,
the
text
does
not
state
that
this
is
the
case.

Groundwater
samples
were
collected
from
multiple
sampling
events
and
analyzed
for
a
reasonable
number
of
parameters
with
low
detection
limits.
Only
two
substances
(antimony
and
lead)
were
detected
at
concentrations
greater
than
MCLs;
however,
elevated
antimony
concentrations
were
noted
in
the
reference
well
sample
which
potentially
indicates
either
high
natural
levels
of
the
substance
or
an
upgradient
contaminant
source.
Elevated
antimony
concentrations
were
only
observed
during
one
of
the
three
sampling
events.
Ash
Grove
Cement
Company
–
Montana
City,
Montana
(continued)

II­
6
The
text
of
the
report
states
that
there
is
no
evidence
that
leachate
from
CKD
is
impacting
groundwater;
however,
14
of
the
21
substances
analyzed
by
the
laboratory
were
detected
at
concentrations
greater
than
background
during
multiple
sampling
events
or
at
sample
locations
indicating
that
the
CKD
source
area
does
impact
the
local
groundwater.
II­
7
CEMEX.,
Inc.
­
Charlevoix,
Michigan
Summary:
There
are
9
CKD
piles
on
the
property.
Investigations
have
been
conducted
to
determine
the
extent
of
the
impact
to
the
local
groundwater
and
to
Lake
Michigan.
The
report
overtly
states
that
there
has
been
an
impact
to
the
groundwater
as
a
result
of
CKD
and
that
pH
levels
and
potassium
concentrations
are
the
best
indicators
of
the
release
due
to
the
variability
of
other
metals
analyzed.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
Results
listed
for
19;
however,
total
and
dissolved
results
are
not
specified
Sampling
dates
or
duration
11/
14/
96,
5/
22/
96,
10/
15/
96,
11/
20/
96,
12/
18/
96,
1/
13/
00,
4/
5/
00,
10/
4/
00,
1/
10/
01,
4/
4/
01,
7/
10/
01
Upgradient
wells
specified
Unknown
Downgradient
wells
specified
Unknown
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
Limited
Contains
conclusions
Limited
References
cited
No
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
­
­
NA
NL
Aluminum
­
­
NA
NL
Ammonia
N
­
­
NA
NL
Antimony
­
­
0.006
0.014
Arsenic
Y
0.025
0.05
5.68E­
5
5/
89
Barium
Y
0.025
2
NL
0/
NA
Beryllium
­
­
0.004
0.004
Bicarbonate
­
­
NA
NL
Cadmium
Y
0.0002
0.005
NL
1/
NA
Calcium
­
­
NA
NL
Carbonate
­
­
NA
NL
Chloride
­
­
NA
NL
Chromium
(total)
Y
0.005
0.1
40
0/
0
Copper
Y
0.025
1.3
1.0
0/
0
Fluoride
­
­
4
NL
Iron
­
­
NA
NL
Lead
Y
0.005
0.015
0.015
0/
0
Magnesium
­
­
NA
NL
Manganese
­
­
NA
NL
­
CEMEX.,
Inc.
­
Charlevoix,
Michigan
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
8
Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
Nickel
­
­
0.1
NL
Nitrate
(as
nitrogen)
­
­
10
NL


Nitrite
(as
nitrogen)
­
­
1
NL

Potassium
Y
NL
NA
NL

Selenium
Y
0.0025
0.05
0.175
14/
4
Silver
Y
0.0025
0.05
0.2
0/
0
Sodium
Y
NL
NA
NL

Sulfate
­
­
NA
NL

Thallium
­
­
0.002
NL

Zinc
Y
0.02
NA
10
NA/
0
Field
Parameters
pH
Y
­
NA
NL

Conductivity
Y
­
NA
NL

TSS
­
­
NA
NL

Dissolved
soilds
­
­
NA
NL

COD
­
­
NA
NL

Organic
Substances
(only
detected
substances
listed)
None
sampled
­
­
­
­

Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
In
the
first
paragraph
of
the
report,
it
is
stated
that
investigations
have
been
conducted
on
the
property
in
accordance
and
under
the
oversight
of
Michigan
Department
of
Environmental
Quality
to
determine
the
impact
of
CKD
to
the
groundwater
in
the
area
and
nearby
Lake
Michigan.
The
results
of
the
investigations
should
be
provided.
An
explanation
about
why
the
Michigan
DEQ
became
involved
with
the
site
should
be
given.

Some
portions
of
the
report
reference
background
concentrations
in
the
groundwater
at
the
property,
but
the
background
well
location
is
not
specified.
The
background
well
should
be
listed
to
address
the
impact
to
the
groundwater.

It
does
appear
that
a
significant
amount
of
sampling
has
been
conducted
on
the
property
during
multiple
sampling
events
conducted
in
1996
and
2000.
Based
on
the
information
provided,
there
has
been
an
impact
to
the
groundwater
of
metals
and
pH.
The
pH,
as
sampled
in
1996,
indicate
levels
ranging
from
approximately
8
to
greater
than
12
with
the
majority
of
results
being
nearer
to
12.
pH
does
not
appear
to
have
been
analyzed
during
the
2000
sampling
event.
It
should
also
CEMEX.,
Inc.
­
Charlevoix,
Michigan
(continued)

II­
9
be
noted
that
the
number
of
metals
sampled
on
the
property
should
be
increased
to
better
assess
the
impact
and
the
nature
of
the
impact.

The
low
HBN
concentration
for
arsenic
dramatically
increases
the
number
of
samples
that
exceed
the
criteria.
Additionally,
the
analytical
detection
limits
for
the
substance
are
considerably
greater
than
the
HBN
value.

As
stated
in
the
report,
groundwater
in
the
vicinity
of
this
property
has
been
affected
by
the
presence
of
CKD
piles.
II­
10
CEMEX,
Inc.
–
Lyons,
Colorado
Summary:
Colorado
Division
of
Minerals
and
Geology
requested
an
assessment
of
the
property
and
the
impact
of
CKD
piles
to
the
local
groundwater.
CKD
has
been
disposed
of
on
the
property
since
1969.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
2
Sampling
dates
or
duration
Unknown
Upgradient
wells
specified
Unknown
Downgradient
wells
specified
Unknown
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
Limited
and
not
relevant
to
groundwater
quality
Contains
conclusions
Limited
and
not
relevant
References
cited
No
Table
2.
Summary
of
report
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
N
­
NL
NL
Aluminum
Y
­
NL
NL
Ammonia
N
N
­
NL
NL
Antimony
Y
0.005
0.006
0.014
0
Arsenic
Y
0.003
0.05
5.68E­
5
0/
1
Barium
Y
­
2
NL
0/
NA
Beryllium
Y
0.004
0.004
0.004
0/
0
Bicarbonate
Y
­
NL
NL
Boron
Y
­
NL
NL
Cadmium
Y
0.005
0.005
NL
0/
NA
Calcium
Y
­
NL
NL
Carbonate
Y
­
NL
NL
Chloride
Y
­
NL
NL
Chromium
(total)
Y
0.01
0.1
40
0/
NA
Cobalt
Y
0.01
NL
NL
Copper
Y
0.01
1.3
1.0
0/
0
Fluoride
Y
­
4
NL
0/
NA
Iron
Y
­
NL
NL
Lead
Y
0.05
0.015
0.015
0/
0
Lithium
Y
­
NL
NL
Magnesium
Y
­
NL
NL
Manganese
Y
­
NL
NL
­
CEMEX,
Inc.
–
Lyons,
Colorado
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
11
Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
Molybdenum
Y
0.01
NL
NL
Nickel
Y
0.04
0.1
NL
1/
NA
Nitrate
(as
nitrogen)
Y
0.01
10
NL
0/
NA
Nitrite
(as
nitrogen)
Y
0.01
1
NL
0/
NA
Potassium
Y
5
NL
NL

Selenium
Y
0.005
0.05
0.175
0/
0
Silver
Y
0.01
0.05
0.20
0/
0
Silicon
Y
­
NL
NL

Sodium
Y
­
NL
NL

Strontium
Y
­
NL
NL

Sulfate
Y
­
NL
NL

Sulfite
Y
­
NL
NL

Sulfide
Y
­
NL
NL

Titanium
Y
0.01
NL
NL

Thallium
Y
0.002
0.002
NL
0/
NA
Vanadium
Y
0.01
NL
0.3

Zinc
Y
­
NL
10

Field
Parameters
pH
Y
­
NL
NL
NA
Conductivity
Y
­
NL
NL
NA
TSS
N
­
NL
NL
NA
Dissolved
solids
Y
­
NL
NL
NA
Total
Inorganic
Carbon
Y
­
NL
NL
NA
Total
Organic
Carbon
Y
1
NL
NL
NA
COD
N
­
NL
NL
NA
Organic
Substances
(only
detected
substances
listed)
None
sampled
Other
Substances
Gross
Alpha
(pCi/
L)
Y
­
NL
NL
NA
Gross
Beta
(pCi/
L)
Y
­
NL
NL
NA
Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.
CEMEX,
Inc.
–
Lyons,
Colorado
(continued)

II­
12
Specific
Comments:
The
first
paragraph
states
that
the
past
assessment
was
"performed
to
the
ultimate
satisfaction
of
the
Division
(Colorado
Division
of
Minerals
and
Geology)"
but
it
does
not
state
what
the
assessment
determined
and
there
is
no
summary
of
any
conclusions
that
were
made.

A
chemical
analysis,
assessment
of
the
local
geology
and
hydrology,
and
analysis
of
groundwater
impacts
have
been
conducted
and
are
included
in
the
past
reports,
but
no
summary
is
included
in
this
report.

Leachate
testing
of
CKD
from
the
property
was
performed
and
a
few
parameters
were
found
to
be
at
concentrations
greater
than
groundwater
standards.
This
type
of
sampling
and
analysis
should
not
be
used
to
replace
groundwater
sampling.
Subsequent
sampling
appears
to
have
only
analyzed
for
the
parameters
that
were
found
to
be
greater
than
groundwater
criteria
during
the
leachate
analysis.
Groundwater
sampling
and
analysis
should
be
conducted
for
any
possible
contaminants,
not
only
the
elevated
substances
detected
during
the
leachate
analysis.
The
groundwater
sample
results
listed
in
the
tables
are
not
addressed,
summarized,
or
referenced
in
the
report.
No
information
is
provided
about
the
monitoring
wells
or
samples
that
have
been
collected
from
them.

In
the
last
paragraph,
a
statement
is
made
that
samples
have
been
collected
from
local
surface
water
and
analyzed
for
the
substances
detected
during
leachate
analysis
of
the
CKD
and
that
no
substances
were
detected
at
concentrations
greater
than
the
standards.
This
is
not
relevant
to
groundwater
quality.

The
analytical
tables
and
groundwater
sampling
events
are
not
summarized
in
any
way
in
the
text
of
the
report
and
it
is
not
known
whether
there
is
any
background
water
quality
information.
There
appears
to
be
only
minimal
impact
to
the
groundwater
based
on
the
given
information;
however,
more
information
and
more
data
should
be
collected.
The
HBN
for
arsenic
is
less
than
the
analytical
detection
limits.

It
is
difficult
to
make
a
conclusion
about
the
quality
of
the
groundwater
in
the
vicinity
of
the
site
without
more
information.
Additionally,
only
two
groundwater
sampling
points
would
not
be
able
to
adequately
characterize
the
groundwater
in
the
area
even
if
the
information
was
available.
II­
13
Essroc
–
Logansport,
Indiana
Summary:
Samples
were
collected
quarterly
from
a
number
of
wells;
however,
specific
information
about
the
sampling
events
or
the
placement
of
the
monitoring
wells
is
not
provided.
The
report
concludes
that
the
data
"indicate
the
apparent
lack
of
impact
on
the
groundwater
of
the
CKD
landfills
at
the
Logansport
plant,"
but
the
report
does
not
provide
sufficient
detail
to
either
support
or
refute
the
given
conclusion.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
12*
Sampling
dates
or
duration
Five
quarterly
sampling
events
­
specific
dates
and
times
not
listed.
Upgradient
wells
specified
3
Downgradient
wells
specified
8
Site
map
included
No
Adequate
physical
description
Limited
Contains
discussion
section
Limited
Contains
conclusions
Limited
References
cited
No
*
One
monitoring
well
not
mentioned
in
the
report
text
is
listed
in
the
data
tables
(EW­
3).
There
is
no
information
concerning
the
well.

Table
2.
Summary
of
reported
data
Sampled
?
DL*
MCL
HBN
(Landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#>
Background
Inorganic
Chemicals
Alkalinity
N
NL
NA
NL
­
NA
Aluminum
N
NL
NA
NL
­
NA
Ammonia
N
N
NL
NA
NL
­
NA
Antimony
Y
NL
0.006
0.014
0/
0
BDL
0
Arsenic
Y
NL
0.05
5.68E­
5
0/
11
BDL­.
012
1
Barium
Y
NL
2
NL
0/
NA
0.16­
0.2
14
Beryllium
Y
NL
0.004
0.0040
0/
0
BDL
1
Bicarbo
nate
N
NL
NA
NL
­
NA
Cadmium
Y
NL
0.005
NL
0/
NA
BDL
0
Calcium
N
NL
NA
NL
­
NA
Carbonate
N
NL
NA
NL
­
NA
Chloride
N
NL
NA
NL
­
NA
Chromium
(total)
N
NL
0.1
40
­
NA
Copper
N
NL
1.3
1.0
­
NA
Fluoride
N
NL
4
NL
­
NA
Iron
N
NL
NA
NL
­
NA
Lead
Y
NL
0.015
0.015
0/
0
BDL
0
Magnesium
N
NL
NA
NL
­
NA
Manganese
N
NL
NA
NL
­
NA
Mercury
(inorganic)
Y
NL
0.002
0.011
0/
0
BDL
0
Nickel
Y
NL
0.1
NL
0/
NA
BDL
1
Nitrate
(as
nitrogen)
N
NL
10
NL
­
NA
Nitrite
(as
nitrogen)
N
NL
1
NL
­
NA
­
Essroc
–
Logansport,
Indiana
(continued)

Sampled
?
DL*
MCL
HBN
(Landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#>
Background
II­
14
Potassium
N
NL
NA
NL
­
NA
Selenium
Y
NL
0.05
0.175
0/
0
BDL
0
Silver
Y
NL
0.05
0.20
0/
0
BDL
0
Sodium
N
NL
NA
NL
­
NA
Sulfate
N
NL
NA
NL
­
NA
Thallium
N
NL
0.002
NL
­
NA
Field
Parameters
pH
N
NL
NA
NL
­
NA
Conductivity
N
NL
NA
NL
­
NA
TSS
N
NL
NA
NL
­
NA
Organic
Substances
(only
detected
substances
listed)
Naphthalene
Y
NL
NA
1.0
NA/
1
NA
1
1,1­
Dichloroethane
Y
NL
NA
9.0E­
4
NA/
1
NA
1
1,1­
Dichloroethene
Y
NL
0.007
NL
0/
NA
BDL
1
CIS­
1,2­
Dichloroethene
Y
NL
0.07
NL
0/
NA
BDL
4
Tetrachloroethene
Y
NL
0.005
0.40
4/
0
BDL
4
1,1,1­
Trichloroethane
Y
NL
0.2
NL
0/
NA
BDL
4
Trichloroethene
Y
NL
0.005
0.008
3/
3
BDL
3
M/
P
Xylene
Y
NL
10
70
0/
0
BDL
1
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
BDL
=
Below
detection
lim
it.

Specific
Comments:
The
report
lacks
any
detailed
information
concerning
the
site
and
the
sampling
events
that
occurred
on
the
property.
Inorganic
contaminants
have
been
detected
at
concentrations
greater
than
background,
but
concentrations
are
less
that
applicable
MCLs.
Organic
contaminants,
not
likely
attributable
to
CKD,
were
detected
at
concentrations
greater
than
MCLs
but
this
occurrence
is
not
addressed
in
the
report.
Due
to
the
very
low
HBN
for
arsenic,
it
is
unlikely
that
the
analytical
method
detection
limits
were
below
this
value.

The
description
of
the
solid
waste
management
units
(SWMU)
located
on
the
property
lacks
any
information
concerning
the
size
of
the
SWMUs
or
details
of
their
use
including
disposal
history.
Chemical
analysis
of
the
waste
material
would
assist
in
determining
the
groundwater
parameters
to
analyze.
In
addition,
site­
specific
information
concerning
property
characteristics,
including,
but
not
limited
to,
site
geology,
topography,
the
size
of
the
property,
and
surrounding
area
is
not
included.

The
description
of
the
eight
groundwater
monitoring
wells
and
the
three
off­
site
residential
drinking
water
wells
does
specify
which
monitoring
wells
are
considered
upgradient
of
the
source
areas
and
that
the
monitoring
wells
located
on
the
property
are
screened
within
the
upper
aquifer;
however,
there
is
no
information
to
support
these
statements
such
as
groundwater
flow
direction
or
groundwater
table
elevations.
The
paragraph
does
not
specify
whether
the
residential
wells
are
screened
within
the
same
aquifer
as
the
monitoring
wells
located
on
the
property.
A
site
map
showing
the
placement
of
the
monitoring
wells
is
necessary
to
support
any
conclusions.
Essroc
–
Logansport,
Indiana
(continued)

II­
15
The
facility
report
states
that
a
risk
assessment
was
completed
for
the
property
and
that
EPA
has
accepted
the
risk
assessment
as
valid;
however,
there
is
no
statement
of
what
the
risk
assessment
concluded.
The
validity
of
the
assessment
does
not
communicate
the
inherent
risk
associated
with
the
property.
Additionally,
a
description
of
the
NOD
should
be
included.

The
facility
report
states
that
only
a
few
substances
are
detected
at
concentrations
greater
than
the
detection
limits,
but
the
detection
limits
are
not
specified
for
any
substances.
It
is
necessary
for
the
detection
limits
to
be
at
concentrations
less
than
the
appropriate
health
based
risk
criteria
for
any
conclusions
to
be
made.
Additionally,
there
is
no
mention
in
the
paragraph
of
the
substances
that
were
detected
at
concentrations
greater
than
the
background
values.
The
text
portion
of
the
report
concludes
that
there
is
an
apparent
lack
of
impact
on
the
groundwater
from
the
site;
however,
this
cannot
be
established
based
on
the
given
information.

The
data
tables
list
substances
that
were
not
detected
at
concentrations
greater
than
the
detection
limits
as
BDL
(below
detection
levels)
but
it
does
not
state
what
the
detection
limits
are.
This
is
important
for
comparability
to
MCLs.
It
also
is
not
stated
whether
the
metals
analysis
is
for
unfiltered
or
dissolved
metals
and
a
number
of
metals
which
would
be
important
to
assess
an
impact
to
groundwater
were
not
analyzed
(i.
e.,
Fe,
Ca,
and
others).
Additionally,
it
is
not
known
whether
EPA­
approved
analytical
methods
were
used
by
the
lab
or
what
sample
collection
methods
were
used
in
the
field.
II­
16
Holnam
–
Ada,
Oklahoma
(Webster
Facility
–
Pontotoc
County)

Summary:
There
are
two
reports
submitted
which
summarize
two
independent
sampling
events.
These
reports
include
a
detailed
summary
of
the
statistical
analysis
of
the
data
results;
however,
general
information
concerning
the
property
and
the
data
results
is
not
included.
This
information
is
needed
to
make
an
accurate
assessment
of
the
quality
of
the
report
and
the
conclusions
that
are
made
in
the
report.

There
are
4
groundwater
monitoring
wells
on
the
property;
one
of
which
is
considered
upgradient
of
potential
sources
of
contamination.
Analytical
data
from
two
rounds
of
groundwater
sampling
is
included
with
the
report.
The
report
states
that
groundwater
elevation
data
also
was
collected
as
part
of
the
sampling
events;
however,
this
data
is
not
included
in
the
report.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
4
Sampling
dates
or
duration
Results
for
two
sampling
events
provided
(08/
2000,
2/
2001)
(report
indicates
monitoring
is
conducted
twice
per
year)
Upgradient
wells
specified
1
Downgradient
wells
specified
3
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
Statistical
analysis
discussed
Contains
conclusions
Conclusion
of
no
impact
based
on
statistical
analysis
References
cited
No
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#>
Backgroun
d
Inorganic
Chemicals
Alkalinity
Y
­
NL
NL
­
NA
0
Aluminum
N
­
NL
NL
­
NA
NA
Ammonia­
N
N
­
NL
NL
­
NA
NA
Antimony
Y
0.02
0.006
0.014
0/
0
<0.02
0
Arsenic
N
­
0.05
5.68E­
5
­
NA
NA
Barium
N
­
2
NL
­
NA
NA
Beryllium
N
­
0.004
0.004
­
NA
NA
Bicarbo
nate
Y
­
NL
NL
­
NA
0
Cadmium
N
­
0.005
NL
­
NA
NA
Calcium
Y
­
NL
NL
­
300­
330
0
Carbonate
Y
0.06
NL
NL
­
<0.06
0
Chloride
Y
­
NL
NL
­
5
–
6
0
Chromium
(total)
Y
0.01
0.1
40
0/
0
<
0.01
0
Copper
N
­
1.3
1.0
­
NA
NA
Fluoride
N
­
4
NL
­
NA
NA
Iron
N
­
NL
NL
­
NA
NA
Holnam
–
Ada,
Oklahoma
(Webster
Facility
–
Pontotoc
County)
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#>
Backgroun
d
II­
17
Lead
N
­
0.015
0.015
­
NA
NA
Magnesium
Y
­
NL
NL
­
23
–
30
0
­
?
Manganese
N
­
NL
NL
­
NA
NA
Mercury
(inorganic)
N
­
0.002
0.011
­
NA
NA
Nickel
N
­
0.1
NL
­
NA
NA
Nitrate
(as
nitrogen)
N
­
10
NL
­
NA
NA
Nitrite
(as
nitrogen)
N
­
1
NL
­
NA
NA
Potassium
Y
1.0
NL
NL
­
2.2
–
3.5
0
­
?
Selenium
N
­
0.05
0.175
­
NA
NA
Silver
N
­
0.05
0.2
­
NA
NA
Sodium
Y
­
NL
NL
­
6.9
­
?
3
Sulfate
Y
­
NL
NL
­
310
­
?
0
Thallium
N
­
0.002
NL
­
NA
NA
Zinc
Y
0.05
NL
10
0/
5
<0.05
–
0.05
4
Field
Parameters
pH
N
­
NL
NL
­
NA
NA
Conductivity
Y
­
NL
NL
­
NA
0
TSS
N
­
NL
NL
­
NA
NA
Dissolved
soilds
Y
­
NL
NL
­
922
–
1,110
0
COD
Y
­
NL
NL
­
25
­
32
1
Organic
Substances
(only
detected
substances
listed)
None
sampled
­
­
­
­
­
Note
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
?
Due
to
the
poor
q
uality
of
the
repro
duction
some
concentration
are
unidentifiable
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
Both
reports
contain
a
relatively
lengthy
section
describing
the
statistical
analysis
that
was
performed
on
the
analytical
results
from
the
two
sampling
events.
The
analysis
indicates
the
relative
variability
of
the
results
and
exceedances
from
the
predicted
values.
However,
at
least
a
portion
of
the
conclusion
should
summarize
the
individual
data
results
in
simple
terms
of
greater
than
background
or
greater
than
the
applicable
regulatory
value.
For
instance,
the
recorded
concentrations
of
zinc
are
consistently
greater
in
the
downgradient
wells
than
in
the
concentrations
from
the
reference
well
during
both
sampling
events.
Additionally,
the
concentrations
also
are
consistently
greater
than
the
HBN
value.
This
clearly
indicates
an
impact
to
the
quality
of
the
groundwater
and
it
is
not
addressed
in
the
data
summary
report.

A
greater
number
of
substances,
primarily
metals,
should
be
analyzed
during
the
sampling
events.
Metals
that
are
indicative
of
CKD
were
not
sampled;
thus,
no
conclusions
of
the
impact
of
these
substances
can
be
determined.

As
previously
stated,
these
two
reports
do
not
contain
site
specific
background
information,
geologic
information,
site
maps,
or
source
area
descriptions.
General
information
necessary
to
assess
the
quality
of
the
report
is
not
included.
There
is
no
summary
of
the
sampling
methods
used
during
sample
collected.
Holnam
–
Ada,
Oklahoma
(Webster
Facility
–
Pontotoc
County)
(continued)

II­
18
The
reports
reference
past
sampling
events;
however,
the
data
from
the
past
sampling
events
is
not
contained
in
the
report.
The
detection
limits
for
antimony
as
listed
in
the
data
table
(0.02
mg/
l)
is
significantly
greater
than
the
MCL
for
the
metal
(0.006
mg/
l).
To
properly
assess
whether
there
is
an
impact
of
antimony
to
the
property,
the
detection
limit
must
be
below
the
MCL.
Additionally,
the
report
indicates
that
antimony
was
detected
during
past
sampling
at
the
property.
It
is
likely
that
the
detection
limit
used
during
that
analysis
is
the
same
as
the
detection
limit
used
in
the
subsequent
analyses.
If
that
is
the
case,
then
there
are
concentrations
of
antimony
significantly
greater
that
the
MCLs
present
in
the
groundwater.
Any
new
sampling
on
the
property
must
properly
address
antimony
before
any
conclusions
of
impact
to
the
quality
of
groundwater
can
be
made.

The
report
indicates
that
sampling
procedures
have
been
inconsistent:
"Additionally,
a
submersible
pump
was
utilized
to
purge
the
wells
prior
to
sampling.
This
change
in
well
purging
may
have
contributed
to
the
detection
of
zinc."
Sampling
methods
should
not
be
altered
between
sampling
events
and
wells
should
always
be
purged
prior
to
sampling
to
ensure
that
a
sample
is
representative
of
the
natural
conditions.
It
is
not
stated
whether
it
was
the
use
of
the
pump
for
purging
the
wells
that
changed
or
the
purging
of
the
wells
itself.
This
should
be
stated.
Purging
wells
by
hand
versus
purging
wells
with
a
pump
should
not
affect
the
resulting
concentration
provided
adequate
sampling
techniques
are
utilized.

Neither
report
definitively
states
whether
there
has
been
an
impact
to
the
groundwater
table
attributable
to
CKD
stored
on
the
property.
The
only
conclusions
of
both
reports
is
that
groundwater
monitoring
on
the
property
should
continue.
First,
more
information
is
needed
to
determine
whether
an
impact
to
the
groundwater
table
has
occurred
and
second,
these
reports
do
not
adequately
address
that
question.
II­
19
Holnam
–
Clarksville,
Missouri
Summary:
The
text
portion
is
brief
and
provides
minimal
information.
Four
wells
have
been
installed
on
the
property
for
regulatory
purposes
and
to
obtain
geologic
and
hydrogeologic
information.
Wells
upgradient
or
downgradient
were
not
identified
in
the
report.
Samples
have
been
collected
from
the
property
during
five
sampling
events
which
have
indicated
stability
of
the
concentrations.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
4
Sampling
dates
or
duration
5
sample
events
(11/
5/
98,
4/
27/
99,
7/
22/
99,
10/
28/
99,
1/
10/
00)
Upgradient
wells
specified
Unknown
Downgradient
wells
specified
Unknown
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
Limited
Contains
conclusions
Not
relevant
to
groundwater
quality
References
cited
No
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
N
­
NL
NL
Aluminum
N
­
NL
NL
Ammonia
N
N
­
NL
NL
Antimony
Y
0.005
0.006
0.014
0/
0
Arsenic
Y
0.005**
0.05
5.68E­
5
0/
1
Barium
Y
0.010
2
NL
0/
NA
Beryllium
Y
0.004
0.004
0.004
0/
0
Bicarbonate
N
­
NL
NL
Boron
N
­
NL
NL
Cadmium
Y
0.001
0.005
NL
0/
NA
Calcium
N
­
NL
NL
Carbonate
N
­
NL
NL
Chloride
Y
1.00
NL
NL
NA/
NA
Chromium
(total)
Y
0.005
0.1
40
0/
0
Cobalt
N
­
NL
NL
Copper
N
­
1.3
1.0
Fluoride
N
­
4
NL
Iron
N
­
NL
NL
Lead
Y
0.003
0.015
0.015
1/
1
Lithium
N
­
NL
NL
­
Holnam
–
Clarksville,
Missouri
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
20
Magnesium
N
­
NL
NL
Manganese
N
­
NL
NL
Mercury
(inorganic)
Y
0.00002
0.002
0.011
0/
0
Molybdenum
N
­
NL
NL
Nickel
Y
0.01
0.1
NL
1/
NA
Nitrate
(as
nitrogen)
N
­
10
NL
Nitrite
(as
nitrogen)
N
­
1
NL
Potassium
Y
1.0
NL
NL
NA/
NA
Selenium
Y
0.005
0.05
0.175
0/
0
Silver
Y
0.005
0.05
0.20
0/
0
Silicon
N
­
NL
NL
Sodium
Y
1.00
NL
NL
NA/
NA
Strontium
N
­
NL
NL
Sulfate
Y
1.0
NL
NL
NA/
NA
Sulfite
N
­
NL
NL
Sulfide
N
­
NL
NL
Titanium
N
­
NL
NL
Thallium
Y
0.002
0.002
NL
0/
NA
Vanadium
N
­
NL
0.3
Zinc
N
­
NL
10
Field
Parameters
pH
Y
NA
NL
NL
NA
Conductivity
Y
NA
NL
NL
NA
TSS
N
­
NL
NL
Dissolved
solids
Y
NA
NL
NL
NA
Total
Inorganic
Carbon
N
­
NL
NL
Total
Organic
Carbon
N
­
NL
NL


COD
N
­
NL
NL

Organic
Substances
(only
detected
substances
listed)
None
sampled
­
­

Other
Substances
Gross
Alpha
(pCi/
L)
NL
NA
NL
NA
Gross
Beta
(pCi/
L)
NL
NA
NL
NA
Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
detection
limit
is
greater
than
regulatory
value
Specific
Comments:
No
background
monitoring
well
is
identified
and
there
is
no
site­
specific
information
contained
in
the
report
or
the
letter
that
is
provided
with
the
data
summary
report.
Holnam
–
Clarksville,
Missouri
(continued)

II­
21
The
only
conclusion
made
in
the
report
is
that
the
concentrations
of
the
substances
detected
has
remained
constant
over
time,
a
conclusion
that
is
not
relevant
to
an
assessment
of
impact
to
the
area.

The
data
itself
does
not
have
a
significant
number
of
substances
detected
at
concentrations
greater
than
MCL
or
HBN
standards,
but
without
definitive
information
concerning
the
location
of
the
wells
and
the
depths
screened,
for
example,
a
conclusion
cannot
be
made
that
there
is
no
impact.
Additionally,
without
information
concerning
the
background
concentrations
of
substances,
it
cannot
be
determined
whether
there
is
an
impact
to
the
local
groundwater
at
concentrations
less
than
regulatory
standards.
II­
22
Holnam
–
Florence,
Colorado
Summary:
The
report
consists
of
three
short
paragraphs
that
briefly
cover
permitting
status,
facility
history,
and
a
brief
conclusion
regarding
groundwater
quality
in
the
vicinity
of
the
site.

Table
1.
Overall
report
quality
Subsurface
No
Total
no.
of
wells
sampled
4
Sampling
Dates
or
duration
3
wells/
4
quarters;
1
additional
well/
5
th
quarter
Upgradient
wells
specified
Not
specified
Downgradient
wells
specified
1
well,
not
named
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
No
Contains
conclusions
Limited
Reference
cited
No
Table
2.
Summary
of
reported
data
Sampled?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
Y
­
NL
NL
NA
Aluminum
Y
0.05
to
0.10
NL
NL
NA
Ammonia­
N
Y
NL
NL
NA
Antimony
Y
0.01
to
0
.2
0.006
0.014
21**/
7**
Arsenic
Y
0.005
to
0.1
0.05
0.0000568
1**/
21**
Barium
Y
0.1
2
NL
0
Beryllium
Y
0.005
to
0.01
0.004
0.004
21**/
21**

Bicarbo
nate
Y
­
NL
NL
NA
Cadmium
Y
0.005
to
0.01
0.005
NL
2**

Calcium
Y
­
NL
NL
NA
Carbonate
Y
­
NL
NL
NA
Chloride
Y
­
NL
NL
NA
Chromium
(total)
N
­
0.1
40
NA
Copper
N
­
1.3
1.0
NA
Fluoride
Y
­
4
NL
0
Iron
Y
0.05
NL
NL
NA
Lead
Y
0.05
to
0.005
0.015
0.015
5**/
5**

Magnesium
Y
­
NL
NL
NA
Manganese
Y
0.01
NL
NL
NA
Mercury
(inorganic)
Y
0.0002
to
0.005
0.002
0.011
2**/
0
Nickel
Y
0.04
0.1
NL
0
Nitrate
(as
nitrogen)
Y
­
10
NL
1
Holnam
–
Florence,
Colorado
(continued)

Sampled?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
23
Nitrite
(as
nitrogen)
N
­
1
NL
NA
Potassium
Y
­
NA
NL
NA
Selenium
Y
0.005
to
0.1
0.05
0.175
6**/
0
Silver
Y
0.01
0.05
0.20
0/
0
Sodium
Y
­
NL
NL
NA
Sulfate
Y
­
NL
NL
NA
Thallium
Y
0.01
to
0
.1
0.002
NL
21**
Field
Parameters
pH
Y
­
NL
­
NA
Conductivity
Y
­
NL
NL
NA
TSS
Y
­
NL
NL
NA
Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
The
quality
of
this
report
is
very
poor
due
to:
(1)
absence
of
site
map,
(2)
absence
of
locational
references
associated
with
monitoring
wells,
(3)
absence
of
background
concentrations,
and
(4)
lack
of
attention
to
statistical
importance,
if
any,
of
results.
The
conclusion
that
groundwater
in
the
vicinity
of
this
site
is
not
influenced
by
placing
CKD
in
the
quarry
is
unfounded
based
on
the
report
and
accompanying
data.
II­
24
Holnam
–
Laporte,
Colorado
Summary:
The
report
appears
to
be
abbreviated,
as
it
provides
only
a
summary
of
analytical
data
collected
over
a
five­
quarter
period.
However,
actual
data
are
only
shown
for
the
first
three
quarters,
with
calculated
differences
shown
for
all
five
quarters
in
separate
tables.
The
text
summary
is
extremely
brief
and
states
only
the
number
and
vague
locations
of
wells,
period
of
sampling,
and
the
conclusion
that
the
"monitoring
wells
were
voluntarily
sampled
for
five
quarters
to
show
that
there
is
no
impact
to
groundwater."

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
3
Sampling
dates
or
duration
Five
sampling
events:
five
consecutive
quarters
beginning
with
1
st
quarter
2000
Upgradient
wells
specified
1
Downgradient
wells
specified
2
Site
map
included
No
Adequate
physical
description
None
Contains
discussion
section
No
Contains
conclusions
No
References
cited
No
Table
2.
Summary
of
reported
data
Sampled?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
#>
Background
Inorganic
Chemicals
Alkalinity
N
­
NL
­
­
Aluminum
N
­
NL
­
­
Ammonia
N
N
­
NL
­
­
Antimony
N
0.006
0.014
­
­
Arsenic
Y
­
0.05
0.000056
8
1/
9
0.01
–
0.027
d
3
>
0.027
Barium
Y
2
NL
0
ND
–
0.014
6
>
0.014
Beryllium
N
0.004
0.004
0/
0
­

Bicarbo
nate
N
­
NL
­
­

Cadmium
N
0.005
NL
­
­

Calcium
N
­
NL
­
­

Carbonate
N
­
NL
­
­

Chloride
Y
­
NL
­
25
­
28
6
>
28
Chromium
(total)
Y
0.1
40
0/
0
ND
d
0
Copper
Y
1.3
1.0
0/
0
ND
d
0
Fluoride
Y
4
NL
0
0.5
–
0.7
6
>
0.7
Iron
Y
­
NL
0
ND
–
0.1
3
>
0.1
Lead
Y
0.015
0.015
0/
0
ND
–
0.013
0
Magnesium
N
­
NL
­
­

Manganese
Y
­
NL
­
0.04
–
0.053
5
>
0.053
Mercury
(inorganic)
N
0.002
0.011
­
­


Nickel
N
0.1
NL
­
­
­
Holnam
–
Laporte,
Colorado
(continued)

Sampled?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
#>
Background
II­
25
Nitrate
(as
nitrogen)
Y
10
NL
0
3.28
–
3.77
0
Nitrite
(as
nitrogen)
Y
1
NL
0
0.04
–
0.66
0
Potassium
N
­
NL
­
­
Selenium
Y
0.05
0.175
2/
0
0.046
–
0.101
0
Silver
N
0.05
0.20
­
­

Sodium
N
­
NL
­
­

Sulfate
Y
­
NL
­
4000
­
4410
0
Thallium
Y
0.002
NL
0
ND
–
0.0007
0
Field
Parameters
pH
Y
­
­
7.5
–
7.6
6
>
7.6
Conductivity
N
­
NL
­
­

TSS
N
­
NL
­
­


NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
d
Dissolved.

Specific
Comments:
Based
on
the
report
which
is
not
dated,
the
following
observations
have
been
made:

General
Conclusion:
The
groundwater
monitoring
wells
were
voluntarily
sampled
for
five
quarters
to
show
that
there
is
no
impact
to
groundwater.

However:
(1)
Not
all
potentially
important
chemicals/
compounds
were
sampled.
(2)
Only
data
for
first
three
quarters
are
explicitly
shown.
(3)
There
are
several
chemicals
that
indicate
higher
values
within
the
downgradient
sampling
areas.
Groundwater
downgradient
of
the
CDK
disposal
area
appears
to
be
influenced,
to
some
degree,
by
increases
in
arsenic,
barium,
chloride,
fluoride,
iron,
and
manganese.
(4)
There
is
no
information
regarding
the
site
description.
II­
26
Holnam
–
Three
Rivers,
Montana
Summary:
The
report
essentially
consists
of
poorly
labeled
data
tables.
The
introductory
paragraph
states
that
there
are
3
wells
(1
upgradient
and
2
downgradient).
However,
the
accompanying
analytical
results
show
data
for
7
monitoring
wells
with
no
indication
as
to
their
association
(relative
position).
As
such,
Table
2
cannot
be
completed
for
background
comparisons.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
3,
but
data
sheets
indicate
7
Sampling
dates
or
duration
Stated:
sampled
twice
per
year
Upgradient
wells
specified
1,
not
indicated
in
analytical
results
Downgradient
wells
specified
2,
not
indicated
in
analytical
results
Site
map
included
No
Adequate
physical
description
None
Contains
discussion
section
No
Contains
conclusions
No
References
cited
No
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
N
­
NL
Aluminum
N
­
NL
Ammonia
N
N
­
NL
Antimony
Y
0.003
0.006
0.014
0/
0
Arsenic
Y
0.003
0.05
0.000056
8
0/
13**

Barium
Y
­
2
NL
0
Beryllium
Y
0.001
0.004
0.004
0/
0
Bicarbonate
N
­
­
NL
Cadmium
Y
0.0001
0.005
NL
0
Calcium
N
­
­
NL
Carbonate
N
­
­
NL
Chloride
Y
­
­
NL
Chromium
(total)
Y
0.001
0.1
40
0/
0
Copper
Y
0.001
1.3
1.0
0/
0
Fluoride
Y
­
4
NL
0
Iron
Y
0.01
­
NL
Lead
Y
0.003
0.015
0.015
0/
0
Magnesium
N
­
­
NL
Manganese
N
­
­
NL
­
Holnam
–
Three
Rivers,
Montana
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
27
Mercury
(inorganic)
Y
0.0006
0.002
0.011
0/
0
Nickel
Y
0.02
0.1
NL
0
Nitrate
(as
nitrogen)
N
­
10
NL


Nitrite
(as
nitrogen)
N
­
1
NL


Potassium
N
­
­
NL

Selenium
Y
0.001
0.05
0.175
0/
0
Silver
Y
0.003
0.05
0.20
0/
0
Sodium
N
­
­
NL

Sulfate
Y
­
­
NL

Thallium
Y
0.003
0.002
NL
0
Vanadium
Y
0.1
NL
0.3
0
Zinc
Y
0.01
NL
10
0
Field
Parameters
pH
Y
­

Conductivity
Y
­
NL

TSS
N
­
NL

Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
Based
on
the
report,
which
is
not
dated,
the
following
observations
have
been
made:

(1)
Not
all
potentially
important
chemicals/
compounds
were
sampled.
(2)
A
comparison
of
background
to
downgradient
samples
is
not
possible
due
to
a
lack
of
monitoring
well
identification.
(3)
There
is
not
sufficient
information
provided
to
draw
conclusions
about
the
impact
of
the
facility.
II­
28
Lafarge
Midwest,
Inc.
–
Alpena,
Michigan
Summary:
The
CKD
landfill
located
at
the
Lafarge
facility
is
both
lined
and
caped.
Groundwater
monitoring
is
conducted
according
to
the
State
approved
Hydrogeologic
Monitoring
Plan
which
includes
annual
sample
collected
from
the
network
of
12
monitoring
wells
at
the
facility
which
includes
background
monitoring.
Continuous
quarry
dewatering
is
also
conducted
in
the
vicinity
of
the
CKD
landfill
which
draws
groundwater
away
from
the
CKD
landfill.

Subsurface
description
No
Total
no.
of
wells
sampled
12
Sampling
Dates
or
duration
2
(6/
28/
00,
6/
7/
01)

Upgradient
wells
specified
Not
specified
Downgradient
wells
specified
Not
specified
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
Limited
Contains
conclusions
Limited
References
cited
No
Summary
of
Reported
Data:

Sampled
?
DL*
MCL
HBN
(land
fill)
#
Exceed
MCL/
HBN
Background
mg/
l*
#>
Background*

Inorganic
Chemicals
Alkalinity
Y
20
NL
NL
NA/
NA
?
?

Aluminum
N
­
NL
NL
­
­

Ammonia
N
Y
0.5
NL
NL
NA/
NA
?
?

Antimony
Y
.0023/.
0
092
0.006
0.014
*/*
?
?

Arsenic
Y
.0044/.
0
.013
0.05
5.68E­
5
0/*
?
?

Asbestos
(>
10
microns)
N
­
7
MFL
NL
­
­

Barium
Y
?
2
NL
0/
NA
?
?

Beryllium
Y
0.001
0.004
0.004
0/
0
?
?

Bicarbo
nate
Y
20
NL
NL
NA/
NA
?
?

Boron
N
­
NL
NL
­
­

Cadmium
Y
0.0002
0.005
NL
0/
NA
?
?

Calcium
Y
?
NL
NL
NA/
NA
?
?

Carbonate
Y
20
NL
NL
NA/
NA
?
?

Chloride
Y
10
NL
NL
NA/
NA
?
?

Chromium
(total)
Y
0.001
0.1
40
0/
0
?
?

Cobalt
Y
0.015
NL
NL
NA/
NA
?
?

Copper*
Y
0.0022/
0.001
1.3
1.0
0/
0
?
?

Cyanide
(as
free
cyanide)
Y
.02/.
005
0.2
NL
0/
NA
?
?

Fluoride
Y
?
4
NL
0/
NA
?
?

Iron
Y
0.020
NL
NL
NA/
NA
?
?
Lafarge
Midwest,
Inc.
–
Alpena,
Michigan
(continued)

Sampled
?
DL*
MCL
HBN
(land
fill)
#
Exceed
MCL/
HBN
Background
mg/
l*
#>
Background*

II­
29
Lead*
Y
0.001/
0.0022
0.015
0.015
3/
3
?
?

Lithium
N
­
NL
NL
­
­

Magnesium
Y
?
NL
NL
NA/
NA
?
?

Manganese
Y
0.020
NL
NL
NA/
NA
?
?

Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
?
?

Molybdenum
N
­
NL
NL
­
­

Nickel
Y
0.020
0.1
NL
0/
NA
?
?

Nitrate
(as
nitrogen)
Y
0.08
10
NL
0/
NA
?
?

Nitrogen
(Nitrate
+
Nitrite)
Y
.037/.
02
11
NL
0/
NA
?
?

Potassium
Y
?
NL
NL
NA/
NA
?
?

Selenium
Y
.042/.
00
28
0.05
0.175
0/*
?
?

Silver
Y
0.0005
0.05
0.20
0/
0
?
?

Silicon
N
­
NL
NL
­
­


Sodium
Y
?
NL
NL
NA/
NA
?
?

Strontium
N
­
NL
NL
­
­


Sulfate
Y
?
NL
NL
NA/
NA
?
?

Sulfite
N
­
NL
NL
­
­


Sulfide
N
­
NL
NL
­
­


Titanium
N
­
NL
NL
­
­


Thallium
Y
.0056/.
0
18
0.002
NL
*/
NA
?
?

Vanadium
Y
0.010
NL
0.3
NA/
0
?
?

Zinc
Y
0.004
NL
10
NA/
0
?
?

Field
Parameters
pH
Y
NA
NL
NL
NA/
NA
?
?

Conductivity
Y
NA
NL
NL
NA/
NA
?
?

TSS
N
­
NL
NL
­
­


Dissolved
solids
Y
?
NL
NL
NA/
NA
?
?

Total
Inorganic
Carbon
N
­
NL
NL
­
­


Total
Organic
Carbon
Y
?
NL
NL
NA/
NA
?
?

COD
Y
5
NL
NL
NA/
NA
?
?

Organic
Substances
(only
detected
substances
listed)

Total
rec
overable
phenolics
Y
0.005
NL
NL
NA/
NA
­


**
detection
limit
is
greater
than
regulatory
value
Specific
Comments:
The
text
of
the
report
states
that
reference/
background
data
is
collected
at
the
site;
however,
no
reference
well
location
is
given.
As
a
result
no
conclusions
can
be
made
concerning
the
quality
of
the
groundwater
on
the
property
in
relation
to
background
conditions.
There
are
a
few
instances
of
accidences
of
MCL
or
HBN
regulatory
criteria
for
lead.
Based
on
Lafarge
Midwest,
Inc.
–
Alpena,
Michigan
(continued)

II­
30
the
number
of
samples
collected
from
the
property
during
the
two
sampling
events
there
does
not
appear
to
be
a
significant
impact
from
the
property
to
the
local
groundwater
but
without
significantly
more
information
concerning
the
location
and
depth
of
the
monitoring
wells,
local
and
regional
geology,
groundwater
flow,
background
information
and
source
area
information
no
conclusions
can
be
made
concerning
the
impact.
II­
31
Lafarge
–
Paulding,
Ohio
Summary:
The
text
portion
of
this
report
is
comparatively
detailed.
The
site
has
6
monitoring
wells
(4
of
which
are
upgradient)
which
are
sampled
twice
annually.
The
location
of
upgradient
wells
are
not
specified
in
the
text,
but
their
locations
are
inferred
based
on
the
information
contained
in
the
report.
The
wells
are
set
at
115
feet
bgs
or
approximately
10
feet
below
the
base
of
the
landfill.

The
report
states
that,
based
on
statistical
analysis
of
the
data,
no
impact
to
the
groundwater
has
been
observed.

Table
1.
Overall
report
quality
Subsurface
description
Some
well
information,
minimal
geologic
information
Total
no.
of
wells
sampled
6
Sampling
dates
or
duration
14
sample
events
(from
9/
95
thru
6/
01);
2
sample
events
for
chemical
analysis
(dates
unknown)
Upgradient
wells
specified
Yes
(inferred)
Downgradient
wells
specified
Yes
(inferred)
Site
map
included
No
Adequate
physical
description
Yes,
of
the
source
areas;
otherwise
limited
Contains
discussion
section
Limited
Contains
conclusions
Statement
of
statistical
analysis
References
cited
No
Table
2.
Summary
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#
>
Background
Inorganic
Chemicals
Alkalinity
Y
NL
NL
NL
0/
0
81­
230
0
Aluminum
N
­
NL
NL
­
­
Ammonia
N
N
­
NL
NL
­
­
Antimony
N
­
0.006
0.014
­
­
Arsenic
Y
0.005
0.05
5.68E­
5
0/
2**
<0.005
1
Barium
Y
0.010
2
NL
0/
0
0.008
–
0.319
0
Beryllium
N
­
0.004
0.004
­
­
Bicarbo
nate
N
­
NL
NL
­
­
Boron
N
­
NL
NL
­
­
Cadmium
Y
0.0005
0.005
NL
0/
0
<0.0005
0
Calcium
Y
NL
NL
NL
0/
0
41
–
210
3
Carbonate
N
­
NL
NL
­
­
Chloride
Y
NL
NL
NL
0/
0
5
–
27
0
Chromium
(total)
Y
0.010
0.1
40
0/
0
<0.01
0
Cobalt
N
­
NL
NL
­
­
Copper
N
­
1.3
1.0
­
­
Fluoride
N
­
4
NL
­
­
Iron
Y
0.01
NL
NL
0/
0
<0.05
6
Lafarge
–
Paulding,
Ohio
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Background
mg/
l
#
>
Background
II­
32
Lead
Y
0.005
0.015
0.015
0/
0
<0.005
0
Lithium
N
­
NL
NL
­
­
Magnesium
Y
NL
NL
NL
0/
0
34
–
130
2
Manganese
Y
0.050
NL
NL
0/
0
<0.05
–
0.03
4
Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
<0.0002
0
Molybdenum
N
­
NL
NL
­
­
Nickel
N
­
0.1
NL
­
­
Nitrate
(as
nitrogen)
N
­
10
NL
­
­
Nitrite
(as
nitrogen)
N
­
1
NL
­
­
Potassium
N
­
NL
NL
­
­
Selenium
Y
0.005
0.05
0.175
0/
0
<0.005
0
Silver
Y
0.010
0.05
0.20
0/
0
<0.01
0
Silicon
N
­
NL
NL
­
­
Sodium
Y
NL
NL
NL
0/
0
15
–
69
2
Strontium
N
­
NL
NL
­
­
Sulfate
Y
NL
NL
NL
0/
0
123
–
680
3
Sulfite
N
­
NL
NL
­
­
Sulfide
N
­
NL
NL
­
­
Titanium
N
­
NL
NL
­
­
Thallium
N
­
0.002
NL
­
­
Vanadium
N
­
NL
0.3
­
­
Zinc
N
­
NL
10
­
­
Field
Parameters
pH
N
­
NL
NL
NA
­
Conductivity
N
­
NL
NL
NA
­
TSS
N
­
NL
NL
­
­
Dissolved
solids
Y
NL
NL
NL
NA
210­
1,100
3
Total
Ino
rganic
Carbon
N
­
NL
NL
­
­

Total
Organic
Carbon
Y
NL
NL
NL
NA
1.9
–
11
0
COD
Y
NL
NL
NL
­
19
­
63
0
Organic
Substances
(only
detected
substances
listed)
None
sampled
­
­
­
­
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value
Specific
Comments:
The
report
provides
a
reasonable
amount
of
detail
concerning
the
source
areas
on
the
property.
There
is
some
information
concerning
the
depth
of
the
monitoring
wells,
but
no
information
about
the
location
of
the
wells
in
relation
to
the
sources.
The
text
also
does
not
state
which
of
the
6
wells
are
located
upgradient
of
the
sources­­
only
that
4
of
the
6
are
upgradient.
The
information
concerning
reference
wells
can
be
inferred
from
the
sample
summary
tables
with
the
exception
of
MW­
1.
Additionally,
a
greater
number
of
wells
are
located
upgradient
than
downgradient
which
should
be
explained.
The
number
of
upgradient
wells
seems
excessive,
and
it
appears
there
should
have
been
more
wells
installed
downgradient
of
the
potential
contaminant
sources.
Based
on
the
analytical
information,
concentrations
of
contaminants
are
below
MCL
values;
however,
a
number
of
substances
are
detected
at
greater
Lafarge
–
Paulding,
Ohio
(continued)

II­
33
concentrations
than
reference
values
indicating
that
there
is
an
impact
to
the
local
groundwater
table
as
a
result
of
the
CKD
piles.
Samples
for
metals
analysis
were
all
field
filtered.
Unfiltered
samples
should
have
been
collected
as
well
for
comparison
to
regulatory
criteria.
Not
enough
information
is
available
to
conclusively
determine
the
impact
from
the
CKD
piles.
The
statistical
analysis
conducted
for
contaminants
was
performed
for
only
a
few
parameters
for
which
there
is
extensive
data.
A
second
method
of
analysis
should
be
used
to
make
a
determination
of
the
data
for
which
there
is
only
two
sampling
events.
II­
34
Lehigh
Portland
Cement
Company
–
Mitchell,
Indiana
Summary:
Lehigh
is
located
in
an
area
of
karst
geology;
therefore,
sampling
of
the
local
surface
water
bodies
is
a
better
indicator
of
groundwater
contamination
than
groundwater
monitoring
wells
and
sample
collection.
Based
on
a
sampling
plan
for
the
property,
samples
would
be
collected
during
multiple
sampling
events
from
periods
of
both
high
and
low
flow
and
from
areas,
both
up
and
downgradient
of
the
property.
Due
to
the
amount
of
time
necessary
for
the
transport
of
the
potential
contaminant
substances
from
the
facility
to
the
sampling
locations,
the
initial
sampling
event
as
summarized
in
the
facility
report
would
need
to
be
used
to
establish
base
line
conditions.
As
part
of
the
summary
report,
samples
were
collected
from
the
low
flow
period.
High
flow
samples
have
not
yet
been
collected
and
would
be
collected
when
sufficient
conditions
exist.
Therefore,
the
data
summarized
in
the
data
tables
cannot
be
used
for
determining
the
impact
of
CKD
to
the
groundwater
table.

It
should
be
emphasized
that
the
location
of
the
landfill
in
an
area
of
karst
geology
makes
the
impact
of
the
landfill
very
difficult
to
assess.
Also,
the
data
collected
and
summarized
in
the
report
represents
base
line
conditions
only
and
are
compared
to
groundwater
regulatory
criteria
for
consistency
with
other
reports.

Table
1.
Overall
report
quality
Subsurface
description
Indicates
only
karst
conditions
exist
–
more
information
is
needed
Total
no.
of
wells
sampled
0
–
Surface
water
collection
points
only
Sampling
dates
or
duration
3
sample
events
during
low
or
standard
conditions
–
30+
samples
collected
during
each
event
(11/
9/
00,
1/
11/
01,
1/
30/
01)
Upgradient
wells
specified
NA
–
upgradient
sample
location
not
specified
Downgradient
wells
specified
NA
–
sample
location
not
specified
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
Limited
Contains
conclusions
Only
states
that
no
conclusion
could
be
made
at
this
time
References
cited
No
Table
2.
Summary
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
Y
NL
NL
NL
NA/
NA
Aluminum
N
­
NL
NL
Ammonia
N
N
­
NL
NL
Antimony
N
­
0.006
0.014
Arsenic
Y
0.005
0.05
5.68E­
5
40/**
Lehigh
Portland
Cement
Company
–
Mitchell,
Indiana
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
35
Barium
Y
0.020
2
NL
0/
NA
Beryllium
N
­
0.004
0.004
Bicarbonate
Y
NL
NL
NL
NA/
NA
Boron
N
­
NL
NL
Cadmium
Y
0.005
0.005
NL
0/
NA
Calcium
Y
1.0
NL
NL
NA/
NA
Carbonate
Y
1
NL
NL
NA/
NA
Chloride
Y
NL
NL
NL
NA/
NA
Chromium
(total)
Y
0.01
0.1
40
0/
0
Cobalt
N
­
NL
NL
Copper
Y
0.01
1.3
1.0
0/
0
Fluoride
Y
NL
4
NL
0/
NA
Iron
Y
0.10
NL
NL
NA/
NA
Lead
Y
0.005
0.015
0.015
0/
0
Lithium
N
­
NL
NL
Magnesium
Y
1.0
NL
NL
NA/
NA
Manganese
Y
0.015
NL
NL
NA/
NA
Mercury
(inorganic)
Y
0.0005
0.002
0.011
0/
0
Molybdenum
N
­
NL
NL
Nickel
N
­
0.1
NL
Nitrate
(as
nitrogen)
N
­
10
NL


Nitrite
(as
nitrogen)
N
­
1
NL

Potassium
Y
­
NL
NL
NA/
NA
Selenium
Y
0.005
0.05
0.175
0/
0
Silver
Y
0.005
0.05
0.20
0/
0
Silicon
N
­
NL
NL

Sodium
Y
NL
NL
NL
NA/
NA
Strontium
N
­
NL
NL

Sulfate
Y
NL
NL
NL
NA/
NA
Sulfite
N
­
NL
NL

Sulfide
N
­
NL
NL

Titanium
N
­
NL
NL

Thallium
N
­
0.002
NL

Vanadium
N
­
NL
0.3

Zinc
Y
0.02
NL
10
NA/
0
Field
Parameters
pH
N
­
NL
NL

Conductivity
N
­
NL
NL

TSS
Y
NL
NL
NL
NA/
NA
Lehigh
Portland
Cement
Company
–
Mitchell,
Indiana
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
36
Dissolved
solids
Y
NL
NL
NL
NA/
NA
Total
Inorganic
Carbon
N
­
NL
NL
Total
Organic
Carbon
N
­
NL
NL


COD
N
­
NL
NL

Organic
Substances
(only
detected
substances
listed)
None
sampled
­
­
­
­

Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value
Specific
Comments:
Areas
of
karst
geology
and
the
impact
from
areas
of
potential
contamination
are
very
difficult
to
assess.
This
report
does
not
provide
enough
information
concerning
the
conditions
that
exist
at
the
site
to
determine
whether
the
sampling
approach
is
appropriate.
For
instance,
the
distance
from
the
site
to
the
sample
locations
for
water
bodies
should
be
included
and
the
water
bodies
receiving
groundwater
from
the
site
and
background
location
have
not
been
specified.
Additionally,
the
report
states
that
conclusions
concerning
an
impact
to
the
groundwater
cannot
be
made
due
to
the
length
of
time
needed
for
the
transport
to
occur.
As
a
result,
there
can
be
no
conclusions
made
at
this
time
concerning
the
impact
or
lack
of
impact
to
the
groundwater
in
the
area.
More
information
and
sampling
events
are
necessary.
Also,
if
contaminants
are
detected
they
may
not
necessarily
be
attributable
to
the
site
–
groundwater
in
the
vicinity
of
the
site
may
travel
and
be
received
by
water
bodies
other
than
the
few
that
are
sampled.
II­
37
Lone
Star
Industries,
Inc.
–
Cape
Girardeau,
Missouri
Summary:
This
summary
report
makes
two
specific
claims:
(1)
the
source
of
elevated
metals
groundwater
concentration
does
not
appear
to
be
the
CKD
Management
Area
because
background
concentrations
are
elevated,
and
therefore,
not
significantly
different;
and
(2)
previous
studies
indicated
that
metals
are
not
leaching
through
the
CKD
to
the
groundwater.
However,
the
report
does
not
contain
a
site
map,
subsurface
description,
methods
of
groundwater
collection
and
analyses,
or
any
indication
as
to
the
relative
locations
of
monitoring
wells
to
one
another
with
respect
to
groundwater
flow
direction.
In
other
words,
there
is
no
way
to
substantiate
or
refute
the
claims
stated
above.
The
monitoring
well
data
indicate
concentrations
of
arsenic,
beryllium,
cadmium,
and
selenium
that
exceed
MCLs.
Silicon
also
is
present
in
relatively
high
concentrations
in
some
wells.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
11
Sampling
dates
or
duration
Annual
sampling
in
most
cases
Upgradient
wells
specified
Not
identifiable
Downgradient
wells
specified
Not
identifiable
Site
map
included
No
Adequate
physical
description
None
Contains
discussion
section
No
Contains
conclusions
No
References
cited
No
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
N
­
NL
Aluminum
N
­
NL
Ammonia
N
N
­
NL
Antimony
Y
0.1
0.006
0.014
6**/
6**
Arsenic
Y
0.001
0.05
0.000056
8
3/
44**

Barium
Y
0.02
2
NL
0
Beryllium
Y
­
0.004
0.004
3/
3
Bicarbonate
N
­
­
NL
Cadmium
Y
0.001
0.005
NL
7
Calcium
N
­
­
NL
Carbonate
N
­
NL
NL
Chloride
N
­
NL
NL
Chromium
(total)
Y
0.01
0.1
40
0/
0
Copper
Y
0.01
1.3
1.0
0/
0
Lone
Star
Industries,
Inc.
–
Cape
Girardeau,
Missouri
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
38
Fluoride
N
­
4
NL
0
Iron
Y
­
NL
NL
Lead
Y
0.1
to
0.001
NL
0.015
13**

Magnesium
Y
­
NL
NL
Manganese
Y
­
NL
NL
Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
Nickel
Y
0.04
0.1
NL
0
Nitrate
(as
nitrogen)
N
­
10
NL
Nitrite
(as
nitrogen)
N
­
1
NL
Potassium
N
­
NL
NL
Selenium
Y
0.001
0.06
0.175
1/
0
Silver
Y
0.001
to
0.01
0.05
0.20
0/
0
Sodium
N
­
NL
NL
Sulfate
Y
­
NL
NL
Thallium
Y
0.1
0.002
NL
0
Vanadium
Y
0.05
NL
0.3
0
Zinc
Y
­
NL
10
0
Field
Parameters
pH
Y
­
NL
NL
Conductivity
Y
­
NL
NL
TSS
N
­
NL
NL
Note
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
Evaluating
the
likelihood
that
the
metals
present
in
the
downgradient
groundwater
are
insignificantly
different
than
background
is
not
possible
due
to
the
lack
of
necessary
information
(site
maps,
geologic
descriptions,
history,
etc.).
In
addition,
references
to
earlier
work,
or
inclusion
of
past
reports,
is
necessary
to
review
potential
historical
impacts
to
the
site.
II­
39
II­
40
II­
41
Lone
Star
Industries,
Inc.
–
Pryor,
Oklahoma
Summary:
This
report
consists
of
one
paragraph
that
briefly
covers
permitting
status,
history,
and
brief
conclusion
regarding
groundwater
quality
in
the
vicinity
of
the
site.

Table
1.
Overall
report
quality
Subsurface
description
No
Total
no.
of
wells
sampled
7
Sampling
dates
or
duration
1999
Upgradient
wells
specified
Not
specified
Downgradient
wells
specified
Not
specified
Site
map
included
No
Adequate
physical
description
No
Contains
discussion
section
No
Contains
conclusions
Limited
Reference
cited
No
Table
2.
Summary
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
N
NA
NL
NA
Aluminum
N
NA
NL
NA
Ammonia­
N
N
NA
NL
NA
Antimony
Y
0.005
0.006
0.014
1/
0
Arsenic
Y
0.005
0.05
0.000056
8
4/
5**

Barium
Y
­
2
NL
0
Beryllium
Y
0.001
0.004
0.004
0/
0
Bicarbonate
N
NA
NL
NA
Cadmium
Y
0.001
0.005
NL
0
Calcium
N
NA
NL
NA
Carbonate
N
NA
NL
NA
Chloride
Y
­
NA
NL
NA
Chromium
(total)
Y
­
0.1
40
0/
0
Copper
Y
0.005
1.3
1.0
0/
0
Fluoride
N
4
NL
0
Iron
Y
0.03
NA
NL
NA
Lead
Y
0.002
0.015
0.015
1/
1
Magnesium
N
NA
NL
NA
Manganese
Y
­
NA
NL
NA
Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
Nickel
Y
0.01
­
NL
NA
Lone
Star
Industries,
Inc.
–
Pryor,
Oklahoma
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
42
Nitrate
(as
nitrogen)
N
10
NL
1
Nitrite
(as
nitrogen)
N
1
NL
NA
Potassium
N
NA
NL
NA
Selenium
Y
0.002
0.05
0.175
0/
0
Silver
Y
0.001
0.05
0.20
0
Sodium
N
NA
NL
NA
Sulfate
Y
­
500
NL
3
Thallium
Y
0.004
0.002
NL
7**
Field
Parameters
pH
N
NA
NL
NA
Conductivity
N
NA
NL
NA
TSS
Y
4.0
NA
NL
NA
Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
The
quality
of
this
report
is
very
poor
due
to:
(1)
absence
of
a
site
map,
(2)
absence
of
geographical
references
associated
with
monitoring
wells,
(3)
absence
of
background
concentrations,
and
(4)
lack
of
attention
to
statistical
importance,
if
any,
of
results.
The
claim
that
the
CKD­
influenced
groundwater
at
this
site
is
limited
to
a
perched
aquifer
cannot
be
confirmed
based
on
the
information
provided.
II­
43
National
Cement
Company
of
California
–
Lebec,
California
Summary:
The
CKD
landfill
has
been
closed
and
a
documented
release
has
occurred.
Long­
term
monitoring
is
being
conducted
to
monitor
for
any
new
releases
from
the
source
area
and
to
monitor
the
existing
conditions.

Table
1.
Overall
report
quality
Subsurface
description
Yes
Total
no.
of
wells
sampled
12
Sampling
dates
or
duration
40
(3/
91
thru
8/
00)
Upgradient
wells
specified
Yes
Downgradient
wells
specified
Yes
Site
map
included
Yes
Adequate
physical
description
Yes
Contains
discussion
section
Yes
Contains
conclusions
Yes
References
cited
Yes
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
C
hemicals
Alkalinity
Y
­
NL
NL
NA
Aluminum
N
­
NL
NL
Ammonia
N
N
­
NL
NL
Antimony
N
­
0.006
0.014
Arsenic
N
­
0.05
5.68
E­
5
Barium
N
­
2
NL
Beryllium
N
­
0.004
0.004
Bicarbonate
N
­
NL
NL
Boron
N
­
NL
NL
Cadmium
N
­
0.005
NL
Calcium
Y
­
NL
NL
NA
Carbonate
N
­
NL
NL
Chloride
Y
­
NL
NL
NA
Chromium
(total)
N
­
0.1
40
Cobalt
N
­
NL
NL
Copper
N
­
1.3
1.0
Fluoride
N
­
4
NL
Iron
N
­
NL
NL
Lead
Y
0.002
0.015
0.015
17/
17
Lithium
N
­
NL
NL
Magnesium
Y
­
NL
NL
NA
Manganese
N
­
NL
NL
Mercury
(inorganic)
N
­
0.002
0.011
Molybdenum
N
­
NL
NL
­
National
Cement
Company
of
California
–
Lebec,
California
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
44
Nickel
N
­
0.1
NL
Nitrate
(as
nitrogen)
Y
­
10
NL
NA
Nitrogen
(Nitrate
+
Nitrite)
N
­
11
NL
Potassium
Y
5.00
NL
NL
NA
Selenium
N
­
0.05
0.175
Silver
N
­
0.05
0.20
Silicon
N
­
NL
NL
Sodium
Y
­
NL
NL
NA
Strontium
N
­
NL
NL
Sulfate
Y
­
NL
NL
NA
Sulfite
N
­
NL
NL
Sulfide
N
­
NL
NL
Titanium
N
­
NL
NL
Thallium
N
­
0.002
NL
Vanadium
N
­
NL
0.3
Zinc
N
­
NL
10
Field
Parameters
pH
Y
­
NL
NL
NA
Conductivity
Y
­
NL
NL
NA
TSS
N
­
NL
NL
Dissolved
solids
Y
­
NL
NL
NA
Total
Inorganic
Carbon
N
­
NL
NL
Total
Organic
Carbon
N
­
NL
NL
COD
N
­
NL
NL
Organic
Substances
(only
detected
substances
listed)
None
sampled
Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
re
gulatory
standard
(MCL
and/
or
HB
N).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
The
report
is
thorough
and
relatively
complete.
It
appears
that
the
rationale
used
for
the
analytical
selection
may
be
sufficient.
The
level
of
detail
in
the
report
and
the
amount
of
sampling
that
has
been
conducted
is
sufficient
to
support
the
conclusions
that
have
been
made
concerning
the
impact
to
the
groundwater
table.
However,
the
facility
should
be
asked
to
provide
any
additional
information
it
has
to
further
substantiate
that
the
parameters
being
monitored
are
adequate.
II­
45
North
Texas
Cement
Company
–
Midlothian,
Texas
Summary:
The
summary
for
the
site
is
fairly
brief
but
included
with
the
summary
report
is
a
copy
of
the
RCRA
Facility
Investigation
which
is
a
detailed
investigation
containing
maps,
figures,
and
a
complete
site
summary.
The
RCRA
report
states
that
there
is
no
impact
to
the
local
groundwater
table
as
a
r
esult
of
the
CKD
landfill
on
the
property.

Table
1.
Overall
report
quality
Subsurface
description
Yes
Total
no.
of
wells
sampled
6
Sampling
dates
or
duration
1
(7/
1997)

Upgradient
wells
specified
Yes
Downgradient
wells
specified
Yes
Site
map
included
Yes
Adequate
physical
description
Yes
Contains
discussion
section
Yes
Contains
conclusions
Yes
References
cited
No
Table
2.
Summary
of
reported
data
Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
Inorganic
Chemicals
Alkalinity
N
­
NL
NL
Aluminum
N
­
NL
NL
Ammonia­
N
N
­
NL
NL
Antimony
Y
0.006
0.006
0.014
0/
0
Arsenic
Y
0.005
0.05
5.68E­
5
0/*

Barium
Y
0.01
2
NL
Beryllium
Y
0.003
0.004
0.004
0/
0
Bicarbonate
N
­
NL
NL
Boron
N
­
NL
NL
Cadmium
Y
0.005
0.005
NL
0/
0
Calcium
N
­
NL
NL
Carbonate
N
­
NL
NL
Chloride
N
­
NL
NL
Chromium
(total)
Y
0.005
0.1
40
0/
0
Cobalt
N
­
NL
NL
Copper
N
­
1.3
1.0
Fluoride
N
­
4
NL
North
Texas
Cement
Company
–
Midlothian,
Texas
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
46
Iron
N
­
NL
NL
Lead
Y
0.003
0.015
0.015
0/
0
Lithium
N
­
NL
NL
Magnesium
N
­
NL
NL
Manganese
N
­
NL
NL
Mercury
(inorganic)
Y
0.0002
0.002
0.011
0/
0
Molybdenum
N
­
NL
NL
Nickel
N
­
0.1
NL
Nitrate
(as
nitrogen)
N
­
10
NL
Nitrogen
(Nitrate
+
Nitrite)
N
­
11
NL
Potassium
N
­
NL
NL
Selenium
Y
0.005
0.05
0.175
0/
0
Silver
Y
0.005
0.05
0.20
0/
0
Silicon
N
­
NL
NL
Sodium
N
­
NL
NL
Strontium
N
­
NL
NL
Sulfate
N
­
NL
NL
Sulfite
N
­
NL
NL
Sulfide
N
­
NL
NL
Titanium
N
­
NL
NL
Thallium
Y
0.01
0.002
NL
0/
0
Vanadium
N
­
NL
0.3
Zinc
Y
0.02
NL
10
0/
0
Field
Parameters
pH
NL
NL
Conductivity
N
NL
NL
TSS
N
NL
NL
Dissolved
solids
N
NL
NL
Total
Inorganic
Carbon
N
NL
NL
Total
Organic
Carbon
N
NL
NL
COD
N
NL
NL
North
Texas
Cement
Company
–
Midlothian,
Texas
(continued)

Sampled
?
DL
MCL
HBN
(landfill)
#
Exceed
MCL/
HBN
II­
47
Organic
Substances
(only
detected
substances
listed)

None
sampled
Note:
Background
well
locations
were
not
identified.
NL
=
Not
listed
as
having
a
regulatory
standard
(MCL
and/
or
HBN).
NA
=
Not
applicable.
**
Detection
limit
is
greater
than
regulatory
value.

Specific
Comments:
The
report
is
thorough
and
relatively
complete,
but
there
has
been
only
one
sampling
event
and
only
a
few
metals
were
analyzed.
The
level
of
detail
in
the
report
would
be
sufficient
to
support
the
conclusions
if
there
were
a
greater
number
of
metals
analyzed
and
the
conduct
of
multiple
sampling
events.
Based
on
the
information
contained
in
the
report,
it
does
not
appear
that
a
release
to
the
groundwater
table
has
occurred
although
a
greater
number
of
samples
should
be
collected
to
support
that
conclusion.
